By: Oleksandr Shchybun, CAMS, MLRO at Remittance360 Ltd
Companies in the financial sector are subject to compliance regulations. As a result, familiarity with the implementation and observance of laws, regulations, and compliance practices becomes difficult. For companies, this can be a serious organizational problem, as it is necessary to create employee training, prepare material, and regularly conduct training in accordance with the job responsibilities of employees. It is necessary to allocate training for compliance officers in order to study the laws and compliance activities in more depth and separately conduct training for other specialists on the presence of compliance requirements in the company, signs of illegal activity, how to report violations, the code of corporate conduct, and other topics that are inherent in the activities of the entire enterprise.
Today, most countries, banks, financial institutions, and a number of non-financial institutions are faced with local and international legislation in the field of prevention of money laundering and financing of terrorism (AML&CTF). An important requirement of the legislation is to ensure proper training of employees.
Germany
According to the German Money Laundering Act, financial institutions must have a continuous anti-money laundering training program in place to regularly inform employees about new methods of dealing with such illegal activities. It is the responsibility of all employees to be familiar with anti-money laundering legislation and to know how to properly conduct customer due diligence in order to avoid financial crimes.
To this end, the country has developed a training program, the European Certified Compliance Professional (ECCP), which aims to provide participants with the necessary know-how and skills to overcome current risks and challenges in the field of compliance. The course consists of various modules covering a wide range of topics and ideally meets practical requirements. The certification promotes the development of competence through a combination of knowledge and applied learning. The course content is provided by an online learning platform, regular online seminars, and passing tests.
German educational institutions offer courses, seminars, and workshops on AML compliance and best practices. These programs are designed to enhance the knowledge and skills of individuals and organizations in AML compliance.
France
In the context of the fight against money laundering in France, financial institutions and other business entities are subject to a comprehensive set of obligations aimed at preventing and detecting money laundering and terrorist financing activities. These obligations are set out, first and foremost, in the French Anti-Money Laundering and Anti-Terrorist Financing Law (LCB-FT) and related regulations. Businesses in France are required to comply with the following key obligation: they must provide ongoing training and awareness programs for their employees to ensure that they are aware of AML and customer due diligence requirements and can detect suspicious activity.
Maintaining a high level of AML awareness and expertise among primary financial monitoring entities’ staff is crucial. Training staff to recognize and report suspicious activity can be challenging, especially for small businesses with limited resources.
Training programs and awareness-raising initiatives are being conducted for professionals in the financial and non-financial sectors. Informing people about the risks of money laundering and detection methods helps to detect suspicious activities at an early stage.
UAE
Establishing an effective anti-money laundering training program for staff is a mandatory requirement for financial institutions and non-financial companies and professions such as precious metals and stone dealers, real estate agents, auditors, and corporate service providers.
Article 21 of Cabinet Resolution No. (10) of 2019 states that the company’s compliance officer must plan, implement, and document an anti-money laundering (AML) training program. Employees must understand their responsibilities, including identifying suspicious transactions/actions, as well as the consequences of non-compliance with laws and regulations.
The main objectives of the anti-money laundering training program are:
• Train staff to identify money laundering and terrorist financing methods and concepts that are relevant to the organization.
• Help employees understand the policies, practices, systems, and controls implemented by the organization in the area of combating money laundering and terrorist financing.
• Coordinate with compliance officers to understand their responsibilities, including reporting suspicions to the Money Laundering Reporting Officer (MLRO).
• Ensure that all employees are aware of their roles and responsibilities in the organization’s efforts to combat money laundering and terrorist financing.
Ukraine
The subject of primary financial monitoring is obliged to take measures in accordance with the legislation to ensure that the responsible employee undergoes training in the field of prevention and counteraction within three months from the date of his appointment, as well as to improve the qualifications of the responsible employee by undergoing training at least once every three years at the relevant educational institution, which falls under the jurisdiction of the specially authorized body, and in other educational institutions in agreement with the specially authorized body.
Thus, compliance training is a necessary component of the overall compliance program at the enterprise, and is also a requirement of the legislation, which indicates precisely the structure of the training and the categories of persons for whom it is intended.
Liga Zakon has a compliance online training program on combating money laundering and terrorist financing. This program allows companies in the financial and non-financial sectors to provide employees with the necessary knowledge, as well as to receive testing to confirm knowledge in an understandable form. The training program is developed using the knowledge and experience of experts in combating money laundering, terrorist financing, and weapons of mass destruction, and meets the requirements of Ukrainian legislation in this area and international standards and modern compliance challenges. The content of the program is sufficient to provide employees with either basic knowledge or more in-depth training as needed, covering money laundering and terrorist financing risks relevant to financial and non-financial organizations.
About the Author
Oleksandr Shchybun is a certified AML specialist (CAMS, USA) and a certified financial crime investigator (Utica University, USA). He specializes in money remittance and card issuing businesses. O. Shchybun has spent more than 15 years working as a compliance officer at a number of financial institutions, including conglomerates such as American Express, MoneyGram, and financial startups, e.g., Remittance360 Ltd. He is based in London, United Kingdom. For more information, you can visit his LinkedIn.
Disclaimer: The information provided in this article is for general informational purposes only and does not constitute legal, financial, or professional advice. Compliance requirements, regulations, and training obligations vary by country, jurisdiction, and industry, and are subject to change. Companies and individuals should consult qualified legal or compliance professionals to ensure they meet all applicable obligations. The author and publisher are not responsible for any decisions or actions taken based on the information in this article, and use of this content is at the reader’s own risk.
